Subject:
Financial Assistance Policy
Issuing Department:
Finance/Revenue Cycle Services Subject Matter Consultation: Legal Services
File Under: _____ Section - _______
Original Date: 12/16/2010
Latest Revision Date: January 1, 2016
1) Page 1 of 13 Approved By:
____________________ Charles L. Johnson, III HHC Executive Vice President & Chief Financial Officer
Purpose: The purpose of this Policy is to set forth the Hartford HealthCare (HHC) policy for the provision of free or discounted Health Care Services to patients who meet the criteria for Financial Assistance. This Policy describes: (i) the eligibility criteria for Financial Assistance, and whether such assistance includes free or discounted Health Care Services; (ii) the basis for calculating amounts charged to patients; (iii) the method for applying for Financial Assistance; (iv) the collection actions that may be initiated in the event of non-payment, including civil collections actions and reporting to consumer credit reporting agencies; and (v) the Hospital’s approach to presumptive eligibility
determinations and the types of information that the Hospital will use to assess presumptive eligibility.
This Policy is intended to comply with Section 501(r) of the Internal Revenue Code and the billing and collection requirements described in Chapter 368z of the Connecticut General Statutes and any regulations promulgated thereunder and must be interpreted and applied in accordance with those laws and regulations. This Policy will be adopted by the governing body of Hartford HealthCare on behalf of its affiliates.
Definitions:
“Eligibility Criteria” means the criteria set forth in this Policy to determine whether a
patient qualifies for Financial Assistance for the Health Care Services provided.
“EMTALA” means the Emergency Medical Treatment and Labor Act, 42 USC 1395dd. “Extraordinary Collection Activity” means a collection action requiring a legal or judicial
process, involving selling debt to another party, reporting adverse information to credit agencies or bureaus, or deferring or denying, or requiring a payment before providing, medically necessary care because of an individual’s nonpayment of one or more bills for previously provided care covered under HHC’s Financial Assistance Policy. The actions that require legal or judicial process for this purpose include 1) placing a lien; 2)
foreclosing on real property; 3) attaching or seizing of bank accounts or other personal property; 4) commencing a civil action against an individual; 5) taking actions that cause an individual’s arrest; 6) taking actions that cause an individual to be subject to body attachment; and 7) garnishing wages.
“Family” means, pursuant to the Census Bureau definition, a group of two or more people
who reside together and who are related by birth, marriage, civil union or adoption. For purposes of this Policy, if the patient claims someone as a dependent on the patient’s income tax return, that person may be considered a dependent for purposes of the provision of Financial Assistance.
“Family Income” means the following income when calculating Federal Poverty Level
Guidelines of liquid assets: earnings, unemployment compensation, workers’
compensation, Social Security, Supplemental Security Income, public assistance, veterans’ payments, survivor benefits, pension or retirement income, interest, dividends, rents, business income, royalties, income from estates, trusts, educational assistance, alimony, child support, assistance from outside the household, and other miscellaneous sources of income. .
“Federal Poverty Level Guidelines” means the federal poverty level guidelines established
by the United States Department of Health and Human Services in effect on the date of the provision of the Health Care Service for awards of Financial Assistance under this Policy.
“Financial Assistance” means free or discounted Health Care Services provided to persons
who, pursuant to the Eligibility Criteria, HHC has determined to be unable to pay for all or a portion of such Health Care Services and to be eligible for free or discounted Health Care Services under this Policy.
“Free Bed Funds” means any gift of money, stock, bonds, financial instruments or other
property made by any donor to a HHC hospital facility for the purpose of establishing a fund to provide medical care to a patient.
“Health Care Services” means (i) emergency medical services as defined by EMTALA;
life-threatening circumstances in a non-emergency department setting; and (iv) medically necessary services as determined by HHC on a case-by-case basis at the provider’s discretion.
“Medically Indigent” means a person who HHC has determined to be unable to pay some
or all of his or her medical bills because the medical bills exceed a certain percentage of the person’s Family Income or Family Assets even though they have income or assets that otherwise exceed the generally applicable eligibility criteria for free or discounted care under the policy. Refer to Appendix A.
“Patient” means person receiving or registered to receive medical treatment or in context
of the policy refers to the person liable for payment.
“Uninsured” means a patient who has no level of insurance or third party assistance to
assist in meeting his or her payment obligations for Health Care Services and is not covered by Medicare, Medicaid, Tricare, or any other health insurance program of any nation, state, territory or commonwealth, or under any other governmental or privately sponsored health or accident insurance or benefit program including, but not limited to workers’ compensation and awards, settlements or judgments arising from claims, suits or proceedings involving motor vehicle accidents or alleged negligence.
“Underinsured” means the patient has some level of insurance or third-party assistance
but still has out-of-pocket Health Care Service expenses such as high deductible plans that exceed the patient’s level of financial resources.
I. Determining Eligibility.
In determining eligibility for Financial Assistance, it is important that both HHC and the patient work collaboratively. Specifically, HHC will do its best to apply the Eligibility Criteria in a reasonable manner and the patient will do his or her best in responding to requests for information in a timely, complete, and accurate manner. If the documentation provided by the patient or his/her family is incomplete or inconsistent with the application we will request clarification to assist in making a decision about eligibility for financial assistance.
1. Eligibility for Financial Assistance. Individuals who are Uninsured or Underinsured, ineligible for any government health care benefit program and unable to pay for their Health Care Services may be eligible for Financial Assistance pursuant to this Policy. Financial Assistance also may be available for individuals who are Medically Indigent. The granting of Financial Assistance shall be based upon an individualized determination of financial need, and shall not take into account age, gender, race, color, national origin, marital status, social or immigrant status, sexual orientation or religious affiliation. The Financial Assistance Application outlines the documents required to verify family size and income.
Further, to be eligible for Financial Assistance, an individual must cooperate with HHC, provide the requested information and documentation in a timely manner, complete the required application form truthfully, and notify HHC promptly of any change in his or her financial situation so that HHC can assess the change’s impact on the individual’s
eligibility for financial assistance.
2. Process for Determining Eligibility for Financial Assistance. In
connection with determining eligibility for Financial Assistance, HHC (i) will require that the patient complete an application for Financial Assistance and provide other financial information and documentation relevant to making a determination of financial eligibility; (ii) may rely upon publicly available information and resources to verify the financial resources of the patient or a potential guarantor; (iii) may pursue alternative sources of payment from public and private payment benefit programs; and (iv) may review the patient’s prior payment history.
3. Processing Requests. HHC will use its best efforts to facilitate the
determination process before rendering services so long as the determination process does not interfere with the provision of emergency medical services as defined under federal law. However, eligibility determinations can be made at any time during the revenue cycle. During the eligibility determination process, HHC will at all times treat the patient or their authorized representative with dignity and respect and in accordance with all state and federal laws.
upon the number of dependents living in the household. In particular, eligibility for Financial Assistance will be determined in accordance with the following guidelines:
(a) Uninsured Patients:
(i) Published rates will be reduced by the percentage defined by the IRS as the amount generally billed using a “look back” retrospective calculation to calculate the amount allowed by governmental and commercially insured patients. This percentage will be updated on an annual basis. The annual calculation methodology and the percentage will be available on hospital websites, and will be provided to patient in writing at their request.
(ii) If Family Income is verified to be at or below 250% of the Federal Poverty Level Guidelines, the patient will qualify for a 100%
discount of the amount generally billed.
(iii) If Family income is verified between 250% and 400% of the Federal Poverty Level Guidelines, the patient will qualify for a 25-75% discount of the amount generally billed.
(iv) A patient may also qualify for Free Bed Funds in accordance with the Hospital’s Free Bed Funds criteria.
(vi) Payment plans will be extended for any patient liability identified in a manner consistent with the Hartford HealthCare’s Payment Plan Policy, a copy of which is available from the Financial Assistance team as provided below and on the Hartford HealthCare and subsidiary websites.
(vii) Refunds will be issued for any payments of $5.00 or more that exceed the patient’s personal liability.
(b) Underinsured Patients:
(i) If Family Income is verified to be at or below 250% of the Federal Poverty Level Guidelines, the patient will qualify for a 100% discount against the patient’s account balance after insurance payments from third-party payors are applied. Amounts generally billed to uninsured patients will be compared to the insured patient’s balance to assure that their personal liability does not exceed that of an uninsured patient.
(iii) A patient also may qualify for Free Bed Funds in accordance with the Hospital’s Free Bed Funds criteria.
(v) Payment plans will be extended for any patient liability identified in a manner consistent with HHC’s Payment Plan Policy, a copy of which is available from the Financial Assistance team as provided below.
(vi) Refunds will be issued for any payments of $5.00 or more that exceed the patient’s personal liability
(c) Medically Indigent:
A Patient will be required to submit a Financial Assistance Application
along with other supporting documentation, such as medical bills, drug and medical device bills and other evidence relating to high-dollar medical liabilities, so that Hartford Health Care can determine whether the patient qualifies for Financial Assistance due to the patient’s medical expenses and liabilities. This discount will be considered after other discounts have been applied and the patient is still unable pay for the Health Care Service provided. This discount will be applied as described in Appendix A. (d) Presumptive Eligibility: Eligibility for Financial Assistance may be presumed based on the patient’s life circumstances. The list below is representative of circumstances under which a patient is deemed to be eligible for a 100% discount without further need to complete a Financial Assistance Application:
1. The patient’s receipt of state-funded prescription programs 2. Participation in Women, Infants and Children programs 3. Food stamp eligibility (SNAP)
4. Subsidized school lunch program eligibility
5. Subsidized housing or other public assistance eligibility
6. Patient states that he/she is homeless and additional due diligence on such status performed and documented
7. Patient is identified to have an income of 250% of the Federal Poverty Level or less, as verified by electronic industry standard software
requesting a free copy by mail by contacting the HHC hospitals’ Patient Access Services department. Additional contact information is provided below. In addition, patients may ask any nurse, physician, chaplain, or staff member from Patient Registration, Patient Financial Services, Office of Professional Services, Case Coordination, or Social Services about initiating the Financial Assistance Application process.
To apply for Financial Assistance, a patient must complete HHC’s Financial Assistance Application Form. The individual will provide all supporting data required to verify eligibility, including supporting documentation verifying income described below. Patients may submit an application up to 240 days from the date on which HHC issues its first, post-discharge billing statement. If an individual has not submitted an application within the first 120 days from the date on which HHC issues its first, post-discharge billing statement, then HHC may begin engaging in the collection actions described below.
Before HHC initiates any collection actions, it will issue a written notice to the last known address of record for the patient (or his/her family) that describes the specific collection activities it intends to initiate (or resume), provides a deadline after which such action(s) will be initiated (or resumed), and includes a plain-language summary of this Policy. HHC may initiate collection activities no sooner than 30 days from the date on which it transmits this written initiation notice, either by mail or electronic mail.
If HHC receives an incomplete application form, it will provide the patient (or his or her legal representative) with a list of the missing information or documentation and give the patient 30 days to provide the missing information. If the patient does not provide the missing information within this period, HHC may commence collection actions (assuming it has provided the written notice described above).
If HHC receives a completed application form, it will make and document eligibility determinations in a timely manner. If an application is deemed complete HHC will provide to the patient or his or her legal representative, a written determination of financial
eligibility within fifteen (15) business days. Decisions by HHC that the patient does not qualify for Financial Assistance may be appealed by the patient, or his or her legal
representative, within fourteen (14) calendar days of the date of the written determination. If the patient or his or her legal representative appeals the determination, the Director of Patient Access (or designee) will review the determination along with any new information and make a final decision within fifteen (15) business days.
Signage and written information regarding how to apply for Financial Assistance will be available in the Hospital emergency service departments and patient registration areas. Once a patient or his or her legal representative requests information about Financial Assistance, a financial counselor will provide the patient or his or her legal representative with the Financial Assistance Application along with a list of the required documents that must be provided to process the application.
Patients may apply for Financial Assistance at any time during the collection cycle process or within 240 days from the date of the first Self Pay notice.
III. Calculating Amounts Charged to Patients
Notwithstanding anything else in this Policy, no individual who is determined to be eligible for financial assistance will be charged more for emergency or other medically necessary care than the amount generally billed to individuals who have insurance covering such care. The basis to which any discount is applied is equivalent to the billed charges posted to a patient account minus any prior insurance payments and adjustments from the patient’s insurance (if applicable).
IV. Relationship to Hartford HealthCare’s Collection Practices.
In the event a patient fails to qualify for Financial Assistance or fails to timely pay his or her portion of discounted charges pursuant to this Policy, HHC reserves the right to institute and pursue Extraordinary Collection Actions (ECA) and remedies such as imposing wage garnishments or filing liens on primary or secondary residences, bank or investment accounts, or other assets, instituting and prosecuting legal actions and reporting the matter to one or more credit rating agencies. For those patients who qualify for
Financial Assistance and who, in HHC’s sole determination, are cooperating in good faith to resolve the outstanding accounts, HHC may offer extended payment plans to eligible patients. For patients who meet the terms of the payment plan HHC will not impose wage garnishments or liens on primary residences, and will not send unpaid bills that are part of the payment plan to outside collection agencies.
No ECA will be initiated during the first 120 days following the first post-discharge billing statement to a valid address or during the time that the patient’s Financial Assistance Application is processing. Before initiating any ECA, a notice will be provided to the patient 30 days prior to initiating such event.
If the patient applies for assistance within 240 days from the first notification of the self- pay balance, and is granted assistance, any ECA’s such as negative reporting to a credit bureau or liens that have been filed will be removed.
(iv) educate all admission and registration personnel regarding the Policy so that they can serve as an informational resource to patients regarding the Policy; and (v) include the tag line “Please ask about our Financial Assistance Policy” in HHC written publications. VI. Covered/Non-Covered Provider List. Attached as Appendix C to this Policy is a list of providers independent of HHC that deliver emergency or other medically necessary care in HHC’s facility and identifies whether the care they provide is (or is not) covered by this Policy. The Board of Directors of HHC delegates the authority to update Appendix C as needed to the Executive Vice President and Chief Financial Officer.
VII. Relation to Free Bed Funds. If a patient applies for Financial Assistance, the Hospital will determine his or her eligibility for Financial Assistance and or Free Bed Funds.
APPENDIX A
Federal Poverty Guidelines Effective January 2015
250%** FPG 275%** FPG 300%** FPG 325%** FPG 400%** FPG Size of Famil y Poverty Guidelin e 100% Awarded 75% Awarded 50% Awarded 25% Awarded 25% Awarded 1 $11,770 $29,425 $32,368 $35,310 $38,253 $47,080 2 $15,930 $39,825 $43,808 $47,790 $51,773 $63,720 3 $20,090 $50,225 $55,248 $60,270 $65,293 $80,360 4 $24,250 $60,625 $66,688 $72,750 $78,813 $97,000 5 $28,410 $71,025 $78,128 $85,230 $92,333 $113,640 6 $32,570 $81,425 $89,568 $97,710 $105,853 $130,280 7 $36,730 $91,825 $101,008 $110,190 $119,373 $146,920 8 $40,890 $102,225 $112,448 $122,670 $132,893 $163,560 *In no case will the Patient’s Balance Due after Discount is applied be more than
10% of annual gross family income
**For families with more than 8 members, add $4,160 (** multiplying factor) for each additional member
Medically Indigent/Catastrophic Financial Assistance*
Medically Indigent/Catastrophic Eligibility:
if patient’s annual gross family income exceeds 400% FPG Balance Due Discount Balance due is ≥ 100% of patient’s annual gross family
income 90% of balance due
Balance due is ≥ 90% of patient’s annual gross family
income 85% of balance due
Balance due is ≥ 80% of patient’s annual gross family income
80% of balance due Balance due is ≥ 70% of patient’s annual gross family
income 75% of balance due
Balance due is ≥ 60% of patient’s annual gross family
income 70% of balance due
Balance due is ≥ 50% of patient’s annual gross family
income 65% of balance due
APPENDIX B
Contact Information for Financial Assistance
Hartford HealthCare Customer Service 1-877-HHC-Bill hartfordhealthcare.org Hartford Hospital
Financial Assistance Clearance Team Main Admitting Department
80 Seymour Street Hartford, CT 06102 1-877-545-3914 hartfordhospital.org
The Hospital of Central Connecticut Financial Counselors
Main Admitting Department 100 Grand Street
New Britain, CT 06050 860-224-5181
thocc.org
MidState Medical Center Financial Counselors Main Admitting Department
435 Lewis Avenue or 455 Lewis Avenue Meriden, CT 06451 Meriden, CT 06451
203-694-8213 203-694-8456
midstatemedical.org midstatemedical.org William W. Backus Hospital
Windham Memorial Hospital Financial Counselors
APPENDIX C
List of Providers Independent of HHC Which Are Covered/Not Covered by the HHC Financial Assistance Policy
With respect to the provision of emergency and medically necessary care in HHC’s facility, care provided by the following independent providers is covered by this Policy: 1. Hartford Medical Group (HHCMG)
2. Employed Physicians of Hartford Healthcare
With respect to the provision of emergency and medically necessary care in HHC’s facility, care provided by the following independent providers is not covered by this Policy:
1. Services provided by Hartford Healthcare affiliates other than those listed in Appendix B are not covered by this policy.
